CHAPTER THREE

Empires, Nations, and Citizenship in the Twentieth Century

WRITING IN THE AFTERMATH of World War II and the Shoah, Hannah Arendt captured the power of citizenship by pointing to its negation. By stripping Jews of German citizenship the Nazis made them nonpersons in the global territorial order, setting the stage for the destruction of a people.1

Jurists and statesmen have recoiled at the notion of the stateless individual, the apatride. International refugees are considered a serious problem because of the liminal position of the refugee between his or her host country and country of origin. Persons displaced within their own countries, who are often numerous and living in appalling conditions, do not produce the same anxieties. Jurists and politicians seem convinced that every person belongs somewhere, and that somewhere is defined in an equivalent way throughout the world, as citizenship in a state.

What kind of state? What meaning does citizenship have when migration and mixing mean that state borders and linguistic or cultural affinity rarely correspond one-to-one, whatever the fiction in play? The conventional narrative of “empire to nation-state” obscures the varied transformations of citizenship in the twentieth century. New forms of empire (the USSR, the Nazis) with widely varying concepts of citizenship appeared even as some of the old ones (Austria-Hungary) were destroyed. Efforts to claim the rights of the citizen within colonial empires existed alongside attempts to seek independence. Although the loss of overseas empires left some western European states more focused on their existence as national political entities, by the 1990s they were looking toward a common European citizenship whose significance had to be worked out.

Citizenship has unquestionably been an important claim-making construct at the level of territorial states—claims for protection against enemy states and against the ravages of disease, old age, and, indeed, of global capitalism. It has been a framework in which people articulate their sense of commonality, with varying degrees of exclusionary and inclusionary sentiments. But the territorial state is not the only form of political belonging on which such aspirations have been focused, and it is not clear that the gains of social citizenship achieved within national frameworks can be defended in the current economic conjuncture.

In this chapter I will look at citizenship at different levels of inclusion, the imperial level among them. Sometimes an overarching citizenship was superposed on national citizenships: the British Commonwealth in 1948, the USSR in 1917, the Russian Federation in 1991, the European Union in 1993. I will also look in the opposite direction, at citizenship within a state, what theorists call group-differentiated citizenship or multinational citizenship, something that actually existed and exists today in India. A variant of differentiated citizenship—permitting people to be citizens in different ways—existed for a time in the country most associated with a unitary conception of citizenship, France.

Claims to make state correspond to nation include both colonized peoples’ quest for liberation and dominant groups’ efforts to purify a space via ethnic cleansing. The dissolution of empires—Ottoman, British, Soviet—did not end conflict over belonging and boundaries. Both world wars of the twentieth century ended with massive, coerced population transfers, the “unmixing of peoples.”2 Political movements have both sought to homogenize populations and to organize diversity. In either case, they confront not just cultural difference per se, but the relationship of difference and inequality—within nation-states, between metropoles and colonies, and among independent states. Poverty and violence send people across borders while others try to defend the boundaries of their supposed civilizations; we are still observing, long after Hannah Arendt wrote, the suffering of people who fall in between.

I ended the last chapter around the time of World War I. Old empires—Ottoman, Austro-Hungarian, Russian—had been troubled, yet during the war their citizens, as much as any, fought loyally and often effectively for them. The Ottomans, with help from the Germans, held off British, French, French African, Australian, New Zealander, and other troops at the Dardanelles and gave the British—who were largely using Indian troops—a tough fight in Basra and Mesopotamia. The downfall of the Ottoman and Austro-Hungarian empires came from choosing what became the losing side in a clash of empires. The Russian Empire couldn’t defeat the onslaught of the German one, but a new variant on Russian empire arose from the debacle, with its own variant on imperial citizenship.

After the war the victors tried to encode new principles of relations among states, but the very act of imperial states imposing the nation-state form on the dismembered parts of losing empires was neither logically consistent nor politically viable. By insisting that the new states of eastern and central Europe corresponded to “nations” but that “minorities” in these states (although not in the territories of the great powers) had to be protected, the dominant powers exposed the poor fit between the newly created citizenships and the actual distribution of people over space. Self-determination, massive expulsions, and the notion of the “minority” were inextricably linked in the politics of Europe, while the League of Nation’s mandate system added a gloss of trans-empire paternalism to the continued power of colonial states over subjects who could, under the new order, be legitimately excluded from citizenship until the ruling power decided otherwise.3 In the ensuing years, some people would strive to push others into the situation of the second-class citizen or exclude them altogether from the polity, while others would demand the full rights of the citizen, whether in an empire that had relegated them to inferior status or in a state that they could label “their own.”

Claiming and Bestowing Citizenship in the British Empire

In 1914, people were British in different ways. In the dominions—Canada, Australia, New Zealand, and South Africa—citizens governed themselves in most respects. The king, nevertheless, declared war on their behalf, although they had the choice of how to fight it. Appeals in legal cases from the dominions could go to the Privy Council in London, and symbols of royal rule not only abounded, but were taken seriously. Although the British government claimed that its subjects had rights anywhere in the empire, it would not interfere with the dominions’ rights to govern themselves—and therefore to exclude British Indians from entry as well as treat their indigenous populations as they saw fit. Indians fought for the empire in large numbers, against the Germans as well as the Ottomans. Africans were recruited with varying degrees of coercion and relegated to porterage or other logistic operations, during which they were fed and treated badly and suffered high mortality from disease.

It was in relation to India that the problem of citizenship and empire was posed with the most immediacy. Indians could enter the United Kingdom, reside there, and even run (and occasionally be elected) for office. But Indians in India had no such status. They had minimal voice in public affairs and faced limits on assembly and speech.4 In classic imperial style, Britain governed India in different ways: through the nominal sovereignty of indigenous elites in the princely states, more directly in other regions. The administrations differentiated people by religion and caste, by designation of certain peoples as “backward tribes” or “backward castes.” The imperial rulers’ relationship to the ruled was arranged into horizontal—and racialized—strata as well as vertical linkages through Indian elites.

Citizenship, in such a structure, was an important category of claim-making. Indian activists could pose their demands in both an imperial framework—on the empire as a whole—and a colonial one—within India—for political voice, social justice, and resources for particular castes or tribes.⁵ From the mid-nineteenth century, the claim to political rights went along with economic and social complaints, first against the “drain” of Indian resources characteristic of an imperial economy, later for a living wage, for free education, for social recognition and material resources for the most subordinated elements of the class structure, for economic planning and redistribution, for redefining the status and role of women within Indian society.6 Claim-making—in localities and in India as a whole—drew on an intense associational life, active journalism despite censorship, and incessant demands from labor, women’s organizations, and others for social reform.⁷

No less a figure than Mohandas Gandhi invoked the notion of imperial citizenship to urge his followers to support the war effort of the British Empire (chapter 2). Political mobilization by the Indian National Congress escalated when Britain reneged on the promises it had made during World War I.⁸ Imperial citizenship became a less appealing claim in the 1920s when the “white” dominions used their autonomous law-making capacity to exclude Indians from entering their territories, negating the right to mobility within the empire that Great Britain had appeared to offer. The South African leader Jan Smuts insisted, “There is no common equal British citizenship in the Empire, and it is quite wrong for a British subject to claim equal rights in any part of the Empire to which he has migrated or where he happens to be living.”⁹ That the British government acceded to arguments like this—as well as its failure to give Indians a serious role in the governing of India—led the Indian National Congress, after long and intense debates, to shift by 1929 from claiming more political power within the British Empire, through variants on imperial federalism, toward making independence the ultimate goal. Congress’s reorientation was not just an instance of nationalism taking its inevitable course toward the nation-state. In Sunil Amrith’s empire-wide perspective, “visions of imperial citizenship foundered on the shoals of white supremacy.”¹⁰

Activists not only had to confront British power by deploying the language of rights and liberalism, but find common ground across a space differentiated by religion, communal affiliation, gender, and social status.11 “Group-differentiated citizenship” emerged out of the differentiations of empire politics as politicians positioned themselves for independence. Mobilizing followers by social category became a way for politicians from the relatively deprived categories—the dalit leader B. R. Ambedkar most prominent among them—to make demands for “their” people. Socially minded elites envisioned reforming India by leveling upward, providing opportunities and recognition to those categories. Alongside the insistence within Indian political discourse, by the 1940s, on the need for “development” and for building a more equitable society, group differentiation encouraged a politics of patronage and of redistribution that reinforced rather than attenuated the particularistic structure of Indian society. Group-differentiated citizenship, after considerable controversy, was inscribed in the Indian constitution of 1950 and underlies the mobilization strategies of political parties to this day.

Controversy raged over including in the Indian constitution mention of social and economic rights—to education, to a minimum level of subsistence, to equality across gender and caste. While most participants in the constitutional debates in India advocated some form of social justice, they disagreed over whether social rights should be distinguished from the more readily justiciable civil and political rights. Was citizenship a sufficient end in itself for constitutional creation, providing the means by which a wider array of rights could be claimed in the future, or should the community express its ultimate goals from the start? In the end, writes Niraja Gopal Jayal, social rights in India remained the “poor cousins of civil and political rights.” Scholars now lament the weakness of a “civic community” at the level of the nation as a whole.¹²

Citizenship in India emerged under the shadow of the violent partition that separated it from Pakistan.¹³ Initially, Indian leaders leaned toward jus soli, with protections for “minority citizens,” but in the frenzy of violence in August 1947 against Muslims in India and Hindus in Pakistan, citizenship legislation took a turn toward the defense of one’s own kind. India wanted to prevent Muslims who had fled India in panic from returning after calm was restored, restricted their ability to claim property they had abandoned, and—a notable violation of citizenship norms elsewhere in the world—refused them access to courts in order to contest these exclusions. Pakistan did likewise. Both countries ended up with something more like jus sanguinis, defining inclusion and exclusion in religious terms and seeking to attract people in the diasporas back to their respective countries. During another period of violence leading up to the secession of East Pakistan from Pakistan in 1971 (creating the new country of Bangladesh), another wave of Muslim refugees trying to enter India reinforced this exclusionary trend in citizenship. “Inflexible citizenship” is how Joya Chatterji characterizes what emerged out of the quite different intentions of Indian and Pakistani leaders at the end of British rule.14

At first glance, group recognition in India seems to offer an historical example of the kind of multinational citizenship that scholars like Will Kymlicka advocate for the future (see the introduction). The example is not a particularly comforting one, for it underscores the pressures for group closure and for clientage that come with linking power and resources to collectivities that emphasize their particularistic basis. The dynamics of group-differentiated citizenship, however, are different in the two contexts. Kymlicka takes as his starting point the civic, democratic constitution of a territorial state, and he seeks the means to provide recognition within it for particular collectivities. Group differentiation in India, in contrast, came out of socially and religiously constituted categories, whose groupness was reinforced by colonial administration. On top of these collectivities, nationalists sought to turn the common ground that the Raj had defined into a fully constituted nation. This national sensibility built on common symbols and structures, but also a legacy of conflict and partition. Juxtaposing political theory and Indian practice emphasizes the difficulty of the question over which theorists have agonized: can one recognize cultural particularity or transcend it while still insisting upon the importance of shared, democratic, inclusive values?15

Trajectories out of the British Empire have been as varied as the forms of governing different peoples within it.¹⁶ The British government learned the lesson of its heavy-handed actions that had precipitated the secession of the thirteen North American colonies in 1776, but the process of devolving power to the “white” dominions played out over more than a century. The ending of Privy Council appeals by citizens of Canada, Australia, and other dominions, as well as the partial suppression of British monarchal symbolism, only took place (and only partially) when the rest of the empire was being “decolonized.”¹⁷

The British pattern of giving colonial governors considerable latitude to conduct administration through structures and political relationships specific to their territory channeled political mobilization to demands for voice within territorial institutions. Territorial administration provided concrete, and by the 1950s attainable, goals to political movements, which came to focus on turning the colony into a self-governing, nationally constituted state. The British government tried at times to attenuate the fragmenting tendencies of its imperial politics by organizing—on a top-down basis—federations in parts of the empire, in Central and East Africa and Malaya for example. The Malayan Federation was the most fully realized, giving rise to the relatively plural state of Malaysia, but not before the repression of a bloody revolution with both ethnic and class elements. The Central African Federation failed because what the government claimed was a structure intended to facilitate economic modernization was perceived—quite correctly—by African nationalists as a ploy to extend the power of white settlers. The East African community, never actually a federation, gave rise after the independence of its constituent states (Kenya, Tanzania, and Uganda) to valiant attempts at creating common markets and infrastructure, but foundered on the unequal geographic distribution of resources as well as disagreements among ruling elites over modes of governance and the territorial basis of each leader’s support.

Alongside all of this came a final British attempt to make the Commonwealth into a meaningful institution. In the twilight of empire, one of the most far-reaching elements of that effort was the attempt to create a post-imperial citizenship, “post” in its roots in imperial citizenship.

In both world wars, the empire had been crucial to the survival of Great Britain, thanks to the enormous contributions of dominions, India, and the colonies. British leaders were conscious after the war that they might need such cooperation again and that Commonwealth territories now had more choice in the matter. When, beginning in 1946, Canada, Australia, and other dominions enacted legislation to define their own nationalities, the British Parliament had to respond. The result was the Nationality Act of 1948. The act created the overlapping statuses of “Commonwealth Citizen” and “Citizen of the United Kingdom and Colonies” alongside that of “British Subject.” In the case of the dominions, it would be up to each to decide who was a national of Canada, Australia, or another dominion, and that nationality would automatically confer Commonwealth citizenship. Concerned in a time of challenge to empire to avoid accusations of racism, Parliament insured that its subjects in the remaining colonies, including Africa and the West Indies, would become “citizens of the United Kingdom and the Colonies.”18

Among the rights that this citizenship conveyed was the right to enter, settle in, and work in the British Isles themselves, although Britain could not force dominions to acknowledge such a right. When the passenger liner Empire Windrush docked in England shortly after passage of the Nationality Act carrying hundreds of West Indians, it unleashed a wave of anxiety about the arrival of what might be a stream of non-white people claiming rights as British citizens. But, as a matter of state policy, the logic of maintaining empire trumped the logic of race, and the people of British colonies now had the right to enter the United Kingdom. In the 1950s, a British Colonial Secretary could assert that the people of the empire “can say Civis Britannicus sum,” an echo of the Civis Romanus sum of the Roman Empire. That so many people from the colonies would actually exercise their new right to install themselves in the United Kingdom was not anticipated by policy-makers, and added to the anxiety many in Great Britain had over nonwhite immigration. Despite mixed motives and misgivings, writes Randall Hansen, “The 1950s were the defining years in the development of multicultural Britain.” The 1948 Act gave people from the colonies and dominions the opportunity to make claims as people who were in some sense British, even if not all people in Great Britain viewed citizens from overseas in such terms.¹⁹

By 1962—when there was no longer much of an empire to maintain—the Nationality Act began to be eroded. The gap between a legally inclusive post-imperial citizenship and discrimination and prejudice in practice widened, until the legal regime caught up with the more exclusionary practices. Restrictive immigration laws—with particular effect on people of African and Asian origin—undermined the possibility of an inclusive Britain in which former subjects would have a place.20

As I will describe below, the Nationality Act of 1948 had parallels to the citizenship clauses of the French constitution of 1946 and the further concessions the French government later made to African leaders. These leaders wanted their own nationalities to be recognized while their inhabitants retained the “superposed” nationality of the French Republic and the Community. The British and French versions of superposed nationality point to the willingness of these two powers to develop some kind of post-imperial political relationship, that, while facilitating the economic and geopolitical interests of the ex-colonial power, conveyed juridically enforceable rights across the space of the former empire to their former subjects.

Citizenship from Tsarist Empire to the Russian Federation

Let us turn to a framework for citizenship quite different from that of the British, one recognizing diverse peoples as elements of a multi-ethnic polity without presuming that sovereignty came from the people or that citizens should govern the state. I am referring to the Russian Empire, the Union of Soviet Socialist Republics, and the Russian Federation. “The pragmatic recognition of the multicultural composition of the empire,” writes Jane Burbank, “was explicit in imperial law.”²¹ Ethnic Russians were only one of the many peoples of the empire, Russian Orthodoxy only one of its recognized faiths. All subjects, including Russians, were the subordinates of the emperor. Relations of tsar to people were vertical, superior to inferior, not the horizontal common belonging of a citizenship regime. But horizontal conceptions were present in people’s expectations that as members of an imperial community they all possessed rights to the tsar’s protection and care.22

Civil and economic rights were allocated according to estate status (nobles, clergy, merchants, peasants), location, religion, work, and combinations of these attributes. Russian peasants did not have the same rights as Russian nobles; Lutherans had different civil rights from those of the Orthodox. The elites of incorporated regions served as imperial intermediaries; some entered the highest ranks of the central government. In the sixteenth century, the Russian Empire acquired a large Muslim population, and Muslim clerics, like Orthodox ones, were given administrative tasks. The government at times moved people around the empire; deportation was part of an imperial repertoire of controlling people. From the time of Peter the Great (1682–1725), the tsarist regime, eager for taxes and recruits, instructed Orthodox priests to keep registers of births and deaths; by the nineteenth century, Catholic priests, Protestant pastors, rabbis, and imams were under similar instructions. Unlike the French état civil (chapter 2), the various registers and official documents of the tsarist regime recorded distinctions of status, religion, and ethnicity until the reforms of 1905–6. During the brief period of quasi-parliamentary rule after that date, reformers sought to erode the importance of estates and underline a direct relationship of individual and state institutions. But classification by “nationality”—Russian, Jewish, Tatar, Polish—remained in the registers and continued to be of importance in Soviet times.²³

In the late nineteenth century, aware of the “civilizing missions” of other imperial powers, the tsarist government promoted Russifying policies, resettled Russian peasants to the east, and encouraged conversion to Orthodoxy. But a thoroughgoing nationalizing policy was not possible; effective governance over the widely dispersed, differentiated population required the accommodation of local elites. Eric Lohr refers to the politics of “separate deals.”24 Poles and Jews were particularly problematic populations, whose rights were adjusted several times in the nineteenth and early twentieth centuries. The Russian state was for a long time cautious about extending formal citizenship rights to foreigners, but increasingly interested in establishing commercial relationships with them. At the same time, the state wanted to hold onto its people and put obstacles in the way of subjects who tried to emigrate.²⁵

The Russian word for “citizenship,” grazhdanstvo, like its Latin and Germanic equivalents, has roots in terms for “city.” In the nineteenth century liberal and radical critics of the autocracy used the term, demanding equal rights for the whole population and referring to alleged western European norms. They confronted Russia’s version of a rights regime: rights handed down by the tsar and adhering to particular categories of people. Those rights were less than inalienable but more than arbitrary, and the differentiation among the tsar’s subjects did not make them less members of the polity.²⁶ Differentiated citizenship set out a field of political action in late-nineteenth- and early-twentieth-century Russia. Some political figures advocated equality; others maneuvered to promote “their” people’s rights within the differentiated system; and still others worked for a revolution that would bring in an entirely new order.²⁷

After the revolution of February 1917 overthrew the Romanov dynasty, reformers in the Provisional Government called for “full ‘citizenship,’ defined as equal rights and obligations before the law for all individual members of the polity.”²⁸ Eight months later the Bolsheviks went back to a citizenship that put more emphasis on the “obligation” side of the equation than the “rights” side. Citizenship in the new Communist state was once again differentiated, this time by another kind of status: “worker” or “peasant” as opposed to “bourgeois” or “noble.”29

A major innovation of the Soviet regime—also building on the imperial past—was the creation of national republics.³⁰ Each was built around a predominant ethnic group. Each would have its own nationality, based on that of the most populous group in the region. The leadership of each republic would come from this dominant ethnic group, mobilized through the Communist Party. The catalogue of nationalities and borders was not fixed, but a politically charged issue. Citizenship of the USSR, like the post-imperial citizenships of France and Great Britain, was superposed on national citizenships.³¹ The significance of citizenship—especially the obligations that went along with the rights—was shaped by the centralizing, revolutionary politics of the Party. Although political rights were minimal, social rights were substantial, not least the right to education. These rights were also allocated in differentiated ways according to class, ethnicity, and place in the party hierarchy.³²

The collapse of the Soviet Union in 1991 meant the reallocation of Soviet citizens among the fifteen successor states. It also meant the loosening of controls on emigration and foreign travel, as well as the opening up of “closed” cities. The picture was complicated by the presence of numerous people in territories that did not correspond to their nationality, both Russians in the newly independent states and non-Russians in the Russian Federation.³³ For a time, the Russian Federation simplified procedures for former Soviet citizens to acquire Russian nationality or to hold dual citizenship, but after 2000 the regime became more restrictive.³⁴ The Russian Federation, true to its name, remained a multinational polity that recognized ethnic and religious particularity through its territorial subdivision into eighty-five components of varying status. Thirty-five different languages are used in administration. The tension between centralizing control and recognition of diversity is a dynamic element in today’s Russian Federation.

Citizenship in the Post-Ottoman Middle East

Although the Ottoman Empire collapsed in the same cataclysm that brought down the tsarist empire, the fate of its citizens took different turns. As late as 1910–11, the possibility that Ottoman citizenship had a place not just for Turks but for Arabs, Greeks, Jews, and others was still alive, even if it was becoming increasingly problematic by virtue of the ascendency of a self-consciously Turkish elite to power. The Balkan Wars, the Armenian genocide, defeat in World War I, the Versailles treaty and the forced breakup of the Ottoman Empire, the struggle that gave rise to the Turkish state, and the forced migrations of Turks and Greeks to “their” respective states violently transformed the relationship of people to space. Post-Ottoman state boundaries were not indigenous creations but impositions of the imperial powers that emerged victorious in World War I.35 The ways in which peoples were allocated to states in these years has bedeviled the region to this day.

Part of the process was supposed to be supervised by international organizations, but the League of Nations and its Permanent Mandates Commission represented more the internationalization of colonialism than the universalization of citizenship.³⁶ Part of the Ottoman territories were divided between France and Britain, and the unequal conflict between two rival “national” claims to Israel-Palestine has been a part of world history ever since, as have the communal conflicts within the newly constructed states of Syria, Lebanon, and Iraq. The mandatory powers did their best—with considerable violence—to avoid the mobilization of populations in these territories, a policy that has not helped to produce a basis for democratic politics or respect for civic rights. Kurds and Palestinians have yet to find a place within the allocation of citizenships, and face serious discrimination in whatever state they find themselves. Both social and religious fragmentation within Middle Eastern countries and memories of past unity under Islamic empires compromise the sense of common purpose of citizenship in the actually existing states. Anti-imperialism, anti-Zionism, and a rather ill-defined pan-Arabism or pan-Islamism have had durable influence in the region, while neither national projects nor some kind of supranational institutions have had sustained traction. The harshness of current global economic relations and the lack of opportunities for upward mobility within national societies adds to the strains. Young men become available for various purposes, from migration to support their families to fighting for the Islamic State.

Sally Cummings and Raymond Hinnebusch contrast the compromised sovereignties of the Middle East with the countries of Central Asia that emerged after 1991 out of the imperial cauldron of tsarist Russia and the Soviet Union and where Islam, albeit in different forms, is also the most important religious affiliation. The two regions share a political style that is personalistic and clientelistic, with little place for legitimate opposition or respect for the civil rights of citizens, but the Central Asian provinces were integrated into a Soviet project that was more “real and meaningful”—with important investments in education and industrialization—than the supposedly liberal policies of European powers in the Middle East. The very lack of a liberal democratic ideal may have enabled the compromises between Moscow and provincial capitals that facilitated both the Soviet regime in the region and the relatively smooth devolution of most of its territories into formal sovereignties with pragmatic relations with Russia and decidedly illiberal governance.37

Subjects, Citizens, and Foreigners: A French Empire Story

Most French people today see their history since 1789 at the opposite end of the spectrum from the histories just described: an “indivisible” republic, in which all citizens have the same rights. Contrary to images of France as a unitary polity moving through time, I will argue that as late as the 1950s, the possibility of an imperial or post-imperial citizenship, incorporative but differentiated, and the possibility of turning empire into federation or confederation were at the core of political interaction and contention between France and its African territories.

The empire in the early and mid-twentieth century was not neatly divided between metropole and colony, its people between citizens and subjects. It consisted of European France; the “old colonies,” such as Martinique and Réunion, where inhabitants including the slaves freed in 1848 were citizens; “new colonies,” notably those of sub-Saharan Africa, where the large majority were considered subjects; Algeria, whose territory was considered an integral part of the French Republic but whose population was divided between settlers, with citizenship rights, and indigenous people, mostly Muslims, who were relegated to the category of subject; protectorates, such as Morocco, Tunisia, and most of Indochina, which were in reality governed by France but formally remained sovereign states with their own nationalities; and (after 1919) former German colonies and Ottoman provinces, mandated to France by the League of Nations and to be governed like colonies but with the presumption that they would eventually develop their own nationalities. In the Quatre Communes of Senegal, original inhabitants had the rights of the citizen without having to give up their civil status as Muslims (chapter 2). In other territories indigenous people who gave up their personal status under Islamic or “customary” law and convinced administrators that they had adopted a French way of life could in principle acquire citizenship. Children of mixed parentage, usually of a citizen father and an indigenous mother, would be citizens if the father recognized his offspring or if the mother or a charitable institution could convince authorities that the child was being brought up in a suitably French manner.³⁸ These narrow passages to citizenship allowed French elites to assert that they adhered to republican ideals while maintaining exclusionary and demeaning practices.

Political movements in Algeria, Indochina, and sub-Saharan Africa focused initially on claiming the full rights of the French citizen. World War I reinforced such claims, for soldiers from across the empire fought and died in the trenches, sharing in a common imperial cause but experiencing racial discrimination in many ways. After the war, leaders in the colonies could assert that their constituents had paid the “blood tax.”

No less a figure than Georges Clemenceau—the wartime prime minister—argued that Algerians’ participation in the war entitled them to become French citizens without giving up their Muslim status. He was in part agreeing with the program of the Algerian political activist known as Emir Khaled calling for citizenship without change of personal status, representation in the Assemblée Nationale, the end of repressive laws, and access to the civil service.³⁹ Meanwhile, influential settlers in Algeria, who possessed the status of the citizen, were arguing that they—but not Muslim Algerians—should not only have full citizenship rights, but also have autonomous authority within Algeria. That demand was intended to insure that a more liberal French government would not, one day, grant Muslim Algerians more rights, and it echoed the demands made by French planters in Saint Domingue in 1789 for both citizenship and autonomy, so that they could keep slaves in their place.40 The government met neither demand.

The political activism of colonial subjects led to a reaction on the part of colonial administrators. In the 1920s, many of them were insisting that citizenship would not be good for Africans and that their progress should occur within their own cultural milieu. This politics of retraditionalization paralleled British colonial policies in Africa, where political ferment and claims to imperial citizenship were countered by an effort to stuff Africans back into tribal containers. Among Muslim Algerians, a variety of claims emerged: for identification with the Muslim world, for recognition of an Algerian nation within the French Empire—or potentially outside it.⁴¹ Aimé Césaire, poet and politician from Martinique, could simultaneously assert that the descendants of slaves who made up the majority of the population of the Caribbean islands shared a cultural connection to Africa—négritude, he called it—and insist on full rights as French citizens and for their territory’s status to be changed from “colony” to “department,” equivalent to that of the political units of metropolitan France. His ally in the négritude movement, Léopold Sédar Senghor of Senegal, also combined a militant assertion of the value of African civilization—alongside and equivalent to European civilization—with a demand for the rights of the citizen for France’s African subjects.⁴²

Those rights had been systematically denied. During the war, both the Vichy regime that ruled most of France’s colonies and the Free French who managed to control French Equatorial Africa paid little attention to previous concerns about subjecting noncitizens to forced labor. Deadly incidents of state violence at war’s end—at Sétif in Algeria and Thiaroye in Senegal, and later in Madagascar—suggested that the repressive might of colonial regimes would continue to be deployed against a variety of challenges. What changed the situation was the postwar government’s realization of its weakness and the need to reconfigure the complex structure of empire if France were to remain something more than a small state on the western fringe of Eurasia.

Devastated by its defeat by Germany in 1940 and its loss of effective control over its most lucrative overseas possession, Indochina, to the Japanese, France founded a new republic, the Fourth. The question of whether a republic could insist that around half of its people were “French” but not citizens resurfaced in a way that reminded some of the debates over citizenship in the colonies that began in 1789. France had to write a new constitution for the new Republic, and that process meant that the future of empire had to be openly debated.

The government began with a name change: the French Empire became the French Union and colonies overseas territories. The government accepted that representatives of the diverse peoples of the empire—including subjects—would have a voice in writing the constitution, but not in proportion to their numbers. The presence of even a small number of overseas deputies—Senghor and Césaire among them—insured that the most profound problems of citizenship in a diverse and unequal polity had to be confronted directly.43

One side in the debates over the constitution insisted that France could only be a great power if it were an ensemble of diverse and equal people. Others worried that France might become “the colony of its former colonies,” given the larger overseas population compounded by the perception that the Union’s subjects were ill-educated and lacked the historical connections and common culture of people who were genuinely French. Such considerations recall the anxieties that had emerged in the debates in the Spanish Empire over the constitution of 1812 (chapter 2). The starting point of the debate in 1946 was the notion that France was an assemblage of peoples, and the relationship of its components could be altered in the interest of preserving the whole.

Conscious of the imperial context, deputies evoked in their debates the edict of Caracalla of AD 212 (chapter 1), interpreting it as conferring citizenship on the entire Roman Empire (except, to be sure, women and slaves) without making them give up their diverse civilizations. Other imperial precedents were cited—the Austro-Hungarian Empire, the Ottomans—and federal precedents as well—the United States, Switzerland, and, even by non-Communist deputies, the system of national republics of the USSR.

In September 1946, overseas deputies argued vociferously to put citizenship rights into the constitution, and at one point boycotted the assembly to demonstrate that the new republic would have no legitimacy overseas if their demands were not met. The wiser heads in the government realized that the acquiescence, at least, of the overseas deputies, however small their numbers, was politically necessary. In the end, the institutions of the French Union created by the constitution were compromises. They kept the real power in Paris, leaving advocates of a post-imperial federalism—entailing autonomy for territories within the larger federation—in the lurch. But Senghor, Césaire, and their colleagues won their minimum demand. The inhabitants of the overseas territories became citizens. Moreover, they did not have to give up their personal status under Islamic or “customary” law. Marriage, inheritance, and filiation—in overseas but not in European France—did not have to come under the civil code. A Muslim man could have more than one wife, vote in an election for the French legislature, and seek a place in a French university or the French civil service. The personal status clause implied recognition of cultural diversity, even if it at times compromised principles of equality—particularly gender equality—in the French Republic.44 The protectorates, such as Tunisia, possessed their own nationalities and thus had a special citizenship status of uncertain significance—as citizens of the French Union—created for them.⁴⁵ But the inhabitants of Senegal, Côte d’Ivoire, and Algeria became citizens of the French Republic.

What this would mean was still subject to the differentiated and contested practices characteristic of imperial polities. The “old colonies” like Martinique achieved the recognition Aimé Césaire had sought for them. They became French departments.⁴⁶ In Algeria, the settler lobby and allies in the French military, business, and political establishment strove to subvert the constitution’s more inclusive intentions. They insured that European settlers, voting in a separate electoral college, would continue to possess political power disproportionate to their number, leaving Muslim Algerians with second-class citizenship and pushing Algeria down a road to violent conflict.⁴⁷

In sub-Saharan Africa, it took ten years to achieve universal suffrage and territorial legislatures with real power. But citizenship there quickly became a claim-making construct: claims for recognition of France’s diversity, for economic and social equality, and for remedying the shortcomings of the constitution. Trade unions pressed for equal pay for equal work and a labor code based on the metropolitan version, a goal African leaders achieved in 1952.

Unlike in the time of Caracalla, citizenship was now hitched to the welfare state, to new norms concerning labor, and to the state’s responsibility for the standard of living of the polity as a whole.⁴⁸ France could no longer neatly segregate its overseas citizens from the social attributes of citizenship. By the mid-1950s, the costs of imperial citizenship were escalating.

Senghor sought to push political reform toward the creation of a layered form of sovereignty: each territory would choose a government with authority over local affairs; French West Africa as a whole would constitute an African federation with a legislature and executive; and this federation would associate with other territories and federations in a reformed French Union in which all inhabitants would be rights-bearing citizens. Basic rights would be guaranteed at the Union level, making them both portable as people exercised their freedom of movement around the Union and insulated from ambitious politicians at the territorial level. The French Union would limit its actions to foreign affairs, defense, development, and other agreed-upon domains and become a confederation, recognizing the national personality of its component parts. Senghor saw nationality not in terms of Senegalese or Ivorians but of Africans, or at least those Africans who shared the French language and the experience of French institutions.

The layering of sovereignty was for Senghor a way of confronting a basic problem that the nationalists of his era and commentators on nationalism of a subsequent time have had trouble dealing with: the theoretical equality among sovereign states and their actual inequality. Senghor called for a combination of two forms of solidarity: “horizontal,” of Africans with each other within and across the territories making up the continent, and “vertical,” of Africans with France, whose superior material resources, educational levels, technical capacities, and experiences with democratic politics had something to offer to Africans. Recognizing inequality was the only way of combating it—as long as Africans could demand equality from a position of strength.

Other African leaders wanted to bypass the West African federation while favoring direct membership of each territory in a Franco-African Community.49 Such possibilities were being debated in Africa as the French government came to realize that it was caught in a trap between following through on the logic of citizenship—which was costly—and the risk of a cycle of rebellion and repression, like that it faced in Algeria, now taking place under the gaze of international institutions and observers who did not see colonial rule as inevitable. The only way to get African leaders to back off their demands for economic and social equality was to give them ever more autonomy in governing themselves.

When the French government in 1958 offered each territory the option of immediate independence or continued participation with a large measure of self-government as Member States of a revised French Community, only Guinea voted for immediate and complete independence. After initial reluctance, the French government accepted demands from African Member States that the Community recognize the right of each state to define its own nationality, which would automatically confer the “superposed nationality” of the French Republic and of the Community. Here is what scholars today call multilevel citizenship.⁵⁰

But African leaders could not agree on whether or how to federate among themselves, and France was anxious to avoid the obligations of too close a union. Africa’s leading politicians came to believe that bilateral relations of sovereign states with France corresponded better to the contingencies of the moment than did layered sovereignty. For a time it looked as if four French West African territories would unite in an African federation, but in the end only two, Senegal and the Sudan, joined up, seriously compromising its chances of success.⁵¹ The new entity was named the Mali Federation after an ancient African empire. It got as far as writing a constitution, briefly governing itself within the French Community, and successfully negotiating with France for independence as a single state. But two months after independence, as Senegalese and Sudanese leaders feared that each was encroaching on the other’s political base, the federation broke up in anger and Senegal and the Sudan went their separate ways (the latter claiming the name of Mali, but as Republic, not Federation). Still, it was only in 1960 that the dissolution of the French Empire in sub-Saharan Africa into territorial nation-states became the only exit option.

Even then, the separation of citizenships implicit in the end of colonial rule was attenuated by bilateral agreements. The French government at the time was more worried that French citizens who wanted to do business, reside in, or possess property in former colonies would become mere foreigners and that their property could be in jeopardy than that former citizens of overseas territories might migrate to France. That France, in the midst of an economic boom, needed labor made the government all the more willing to see its former citizens come to its places of work. The independence treaties conveyed reciprocal rights similar to those previously conveyed by common citizenship, minus political rights but including the right of former citizens to enter and reside in France and current French citizens to do likewise in former colonies. Moreover, the French government decided that anyone born a citizen before the date of independence of a former overseas territory could have his or her French nationality recognized—as opposed to applying for naturalization—as long as the individual established residence within the current boundaries of the French Republic. France even went so far as to change its constitution to allow a former territory to remain a Member State of the Community after becoming independent. In actuality, the Community was no longer a functioning entity, but the episode reveals the desperation of the French government to bind former citizens—if no longer its colonial territories—to itself. It was for a time extending to its former citizens one of the most important rights they had won in 1946: to enter, reside in, and seek education or employment in European France.

Treaties can be abrogated and laws changed more easily than constitutions. When the French government, in 1974, decided to move to a more restrictive citizenship regime, there were no more Africans in its political institutions and the decision was its to make. The new laws cut off immigration of workers and wound down the special regime to which its former overseas citizens were entitled, although it allowed properly documented citizens to bring in certain categories of relatives.

The new laws defined a gap—indeed a canyon—between people entitled to the security and benefits of French citizenship and people who were present in France, often at work, without legal authority. Those people began to call themselves the “sans papiers,” the undocumented.52 The separation of citizenships encouraged many French people to insist that there was a basic distinction between “Français de souche,” French people who claim the historical heritage of Frenchness, and others, including people with proper citizenship status but marked as “issus de l’immigration,” coming from immigration. Such a distinction is behind the development of a xenophobic far right in France. But among defenders of French republican and egalitarian traditions, many insist that equality among citizens means that there is only one way to be French, and anybody who does not conform to those (not entirely clear) expectations was guilty of “communitarianism” and endangered the coherence of the Republic.⁵³ What is easily forgotten is that the French constitution of 1946 (and its successor of 1958) specified in its personal status clause that one could be French in more than one way.

The constitution of 1946 was not the result of a more generous, inclusive sentiment among French people, but reflected reasons of state. France was trying to hold together what it had once called an empire, then a Union, later a Community. Once France gave up its empire, those reasons of state no longer applied.54 In this context, the myth of an unbroken line of French citizenship from 1789 to the present had its uses for different sides—for some to articulate a more national conception of the polity, for others to claim economic and social equality within the French nation. Nevertheless, that so many actors from 1945 to 1960—African and French—tried to find new formulas for preserving an inclusive citizenship in a diverse and unequal political body is a lesson worth remembering in a world that remains diverse and unequal.⁵⁵

Citizenship and the Nation-State in Post-Imperial Africa

And what of citizenship in Africa after the end of empire?⁵⁶ The picture is mixed. One side is the vigor with which some Africans have defended the citizen’s right to a voice in politics. In 2012, when the incumbent president of Senegal, Abdoulaye Wade, tried to manipulate the electoral system to perpetuate his power—first by allowing himself to get around term limits to run for a third turn, then by fiddling the electoral rules in his favor—young people in Dakar and other cities took to the streets. Rap musicians played a key role in mobilizing youth. The demonstrations succeeded in blocking Wade’s electoral manipulations and—to the surprise of some of my Senegalese friends—the elections turned out to be reasonably fair and resulted in Wade’s defeat and the installation of Macky Sall as president.57 A couple of years later, when Blaise Campaoré, president of Burkina Faso, tried to extend his 27 years in power, similar demonstrations erupted and Campaoré was forced to flee the country and new elections were held. An attempt by Campaoré’s praetorian guard to restore him failed in the face of popular demonstrations led by organizations with names like Balai citoyen (citizen broom), Citoyen africain pour la renaissance (African citizen for the renaissance), and Front de résistance citoyenne (citizen resistance front).⁵⁸ In other countries as well there has been resurgence of political debate—in print, on radio talk shows, in “radio trottoir” (the street). Such debates have brought out both attachment to states as they exist today—to Uganda, to Kenya, to Benin—and insistence on the part of at least a portion of the public that the state respect the demands and expectations of its citizens.⁵⁹

Claim-making in the name of citizenship—for political voice and fair elections, for equitable treatment of workers, for public services—does not necessarily triumph. The mobilization of citizens in African countries confronts not just the repressive power of the state but relationships that seem to offer more protection or opportunities than the collective action of citizens: poor people seeking wealthy patrons or people relying on the support of ethnic or religious communities.⁶⁰ It confronts as well a global economic order in which African states have limited means to fulfill the expectations of their citizens for a decent standard of living.

Citizenship in its national sense is not always an unmitigated blessing; it can be the basis of xenophobic politics as well as civic order. In South Africa, mobs of young men have beaten and sometimes killed immigrants from neighboring countries who were selling things on the street or seeking low-skilled work. The mobs proclaim the desire to keep jobs in South Africa in the hands of South Africans. They do not recall the importance of regional connections in the struggle against apartheid. Such xenophobic behavior reflects, in this instance, the triumph of state-defined boundaries over webs of connection that at one time were important parts of people’s lives.61

Similarly, the Côte d’Ivoire had long attracted migrants from a wide region, and it shared with the people of neighboring states a history of mobilization to make meaningful a common French citizenship.⁶² But even while the debate over federation and confederation was ongoing in French West Africa, a pogrom took place in Abidjan in 1958, led by “native” Ivorians—and not the poorest among them—against workers from Dahomey and Togo who had “taken” jobs from local people.

The riot was an embarrassment to Félix Houphouët-Boigny, the leading politician from the Côte d’Ivoire. Although he opposed the African federation advocated by Senghor in favor of the direct participation of African territories in a French federation, Houphouët-Boigny did not take a narrow view of what political belonging meant in Africa. His career had taken off in 1944 when he organized an effort to ban forced labor in French Africa. It was people from the north of the Côte d’Ivoire or the neighboring French territories of Upper Volta, Sudan, and Niger who had been forcefully recruited to work for white planters in the fertile and well-watered southern Côte d’Ivoire. The end of forced labor liberated not only the laborers, but the African farmers of the coastal region, who now could get labor that had heretofore been reserved for whites. Coming to power with independence in 1960, Houphouët-Boigny understood quite well that the economic development of his territory depended on people from elsewhere in former French Africa. Moreover, in 1946 he had helped to found a political party (of which he remained president) with branches in every territory of French Africa, confronting the French government with an expression of African solidarity.

After his disappointment at not being able to enact the French federation that he sought, Houphouët-Boigny nonetheless tried to develop an inclusive version of Ivorian citizenship.63 He wanted citizens of neighboring states whose leaders were his political allies to have the rights of the Ivorian citizen when they were within the country, giving up those rights when they left. Neither his own cadres nor the leaders of other states accepted his proposition; they had a narrower view of citizenship. But Houphouët-Boigny was a master at forging personal ties to the elites of different ethnic groups within his country’s diverse population. He remained in power for 33 years. When he died in 1993, the vertical ties he created disappeared with him, and his successors lacked his ability and legitimacy and faced a situation where the export economy was in crisis and jobs were scarce.

As politicians from the northern region of Côte d’Ivoire contended for leadership, others tried to exclude them on the grounds that their parents were from neighboring states. Such was the fate of Alassane Ouattara, the leading opponent of the incumbent president. The exclusionary faction, eventually headed by President Laurent Gbagbo, talked of “ivoirité,” the quality of being a genuine Ivorian, a truly autochthonous member of the Ivorian nation.⁶⁴ Tensions were high between citizens from the northern Côte d’Ivoire suspected of foreign origins and southerners who saw themselves as true Ivorians. The government tried to restrict “foreigners’ ” access to land. The crisis turned into a struggle for the state, degenerating into a civil war in 2011 when Gbagbo refused to accept the results of an election that had voted in Ouattara. The conflict ended when France and the association of West African states sent troops, who helped the militias of Ouattara and installed him in power. His presence reversed the exclusion of northerners from full Ivoirian citizenship, but not the tendency toward ethnic factionalism and favoritism.

Projecting a reified notion of the true citizen—Ivorian, Zambian, Tanzanian—and defining rivals as “foreign” is one way in which ruling elites used the resource of sovereignty to keep themselves in power. As Thandika Mkandawire astutely remarks, “The problem is not so much that the nationalists accepted existing colonial borders, but rather that this acceptance gave individual states carte blanche in terms of what they could do to their citizens within these borders.”65

There are other ways to look at the citizenship question in Africa. Many observers, African and otherwise, believe that most Africans focus their sense of themselves and the relationships that provide access to the most basic resources through a primary attachment to communities defined by language, shared social practices, and a putative common history. To acquire land in much of Africa, for instance, the citizen often cannot simply act like an anonymous individual, pay his or her money, and expect courts or other state institutions to guarantee property. In rural areas, the individual may need to be an accepted community member to have access to land. “One first needs to be recognized as a ‘son’ or ‘daughter’ of a local community,” writes Carola Lentz in reference to Ghana, and it is through such recognition that “one enjoys full rights over landed property and can legitimately partake in local political affairs.”⁶⁶ She claims that only five percent of land in West Africa comes under the kind of regime of title documentation that state courts can readily enforce. Many claims to land are based on a “first-comer narrative,” an historical claim of belonging to a community that was the “original” occupant of the land—a claim requiring witnesses and testimony and often entailing conflict. Such claim-making can be adaptable to economic incentives and political changes, and, Lentz argues, is not necessarily incompatible with agricultural development. But it assumes a particularistic pattern of belonging, with deep roots in local histories, that exists in tension with the formalized belonging that citizenship in a territorial state implies. Focusing land issues on local hierarchies can have important political consequences, as Catherine Boone points out: “By segmenting communities along communal lines and shoring up hierarchy within them, the neocustomary land regimes have also worked to containerize land politics in ethnic jurisdictions, tamp down the scale of politics, and reproduce ethnicity as the basis of politics.”67

Particularly in the early years after independence, radical African leaders like Sékou Touré of Guinea and Modibo Keita of Mali viewed indigenous societies as feudal, dominated by chiefs who kept former slaves—and women more generally—in a state of voicelessness, subordination, and precarious access to land. Citizenship in a new nation promised liberation and equality. Their diagnosis was often to the point, their remedies not necessarily emancipatory. Many people from highly stratified societies took the task of liberation into their own hands by migrating to cities or neighboring countries.⁶⁸ In other contexts, elites defined the good citizen—who might be awarded accordingly—as one who supported the leader or the party, weaving citizenship and clientage into a single pattern.⁶⁹

The ethnic fragmentation of African societies could make it easier for governing elites to defend their own power, as long as the cooperation of regional elites could be assured by a mixture of patronage and coercion. In South Africa, which has what many consider the world’s most progressive constitution, the government has at times backed the power of chiefs in the areas that the previous, white-dominated regime had designated for African settlement, conferring on them the power to allocate much of the land. In these instances “rural people are no longer considered to be rights-bearing citizens, with the capacity to enforce their land rights against the state and others.” In other situations the government oscillates between conflicting imperatives: its desire to develop individual property ownership and “responsible” economic behavior by rural cultivators, its need to acknowledge the association that many South Africans make between the citizenship they acquired in 1994 and access to land, and the variability and complexity of power relations in different parts of the country. Citizenship in South Africa has not produced a unified, horizontal society, but a highly differentiated and unequal one.70

Within states, political actors try to draw on both “civic” ties—to the state, its institutions, and the national collectivity—and “traditional” ties—to villages, ethnic groups, kinship networks—in order to attach supporters to their cause. Political parties contesting elections call on a variety of social ties to mobilize voters—as they do in many parts of the world.⁷¹ Some consider that such strategies accentuate “tribalism,” but in any case politicians are working with social structure in all its complexity, not with an ideal type of the anonymous individual in relation to the state.

The idea of “belonging” in Africa before colonization did not necessarily mean that the continent was divided into distinct communities each of which was blessed with a strong sense of commonality and equality. Distinctions of gender, age, class, and status are as much part of African history as of any other.⁷² Arguably, differentiation within communities has become starker over time: with growing population in many parts of rural Africa, more pressure on access to land, and scarce jobs, a vast number of people have more to demand from a small number of potential patrons with access to resources at both local and national levels. Such circumstances, even in instances of regular elections and relatively open media debate, place a higher premium on the vertical ties of patronage than on the horizontal notions of civic belonging, impartial rule of law, and equal political voice.73

It would be a mistake to consider a vision of citizenship that focuses on civic attachment to be the virtuous twin of ethnic citizenship. Both can be bounded and exclusionary or both can imply recognition of others’ equivalent claims. Neither necessarily implies empathy toward people who fall in between categories, notably refugees. A lot depends on context.

Civic and ethnic citizenship can be in dynamic tension with each other. Juan Obarrio worries that the emergence of what he calls “customary citizenship” in Mozambique renders democracy incomplete. Coming to power in 1975, after a bitter and bloody struggle against the Portuguese colonial regime, the government tried in vain to suppress customary authority in the name of a unified, socialist citizenry. Having given up that battle, it now recognizes community courts that enforce the legal norms of particular ethnic groups, as articulated in many instances by “traditional” chiefs. Something like the ethnically defined colonial subject thus creeps back into the status of the Mozambican citizen. Elisio Macamo, in contrast, sees the problem in Mozambique less as the return of “customary” norms and authority than a combination of revolutionary arrogance and clientelism: the triumph of a liberation movement that saw its role as educating the populace rather than listening to it, and that insisted (even after losing its socialist fervor) on having its way, creating a “political culture which is deeply hostile to citizenship.” Jason Hickel, meanwhile, sees the problem from a different angle. His studies in Zulu-speaking areas of South Africa suggest that many people see no place for themselves in the unitary, civic notion of citizenship preached for many years by the African National Congress. Instead, they place value on respect for elders, for local hierarchies, for maintenance of the kinship structure, for a gendered division of labor, all of which they see as “crucial to collective well-being.” Hickel’s goal is not to excuse antidemocratic practices, but to point to the powerful reasons why not everyone in Africa eagerly embraces the values of liberal democracy.74 The question these accounts leave us with is whether conceptions of democratic and customary citizenship, of civic engagement and patron-client relations, are locked in a zero-sum game, or whether individual freedom, collective belonging, and hierarchical relationships can be reconciled. We are confronted not with an inherent characteristic of Africa, but with variations on a fundamental problem in studying citizenship.

Some scholars belittle the regularizing structures of elections and negotiations as European imports while celebrating patron-client relations—punctuated by the “unruly” intervention of popular classes—as means of making claims on the state. Patrons do distribute resources, and mass unrest can force governments to make concessions. But it is unlikely that patrons will continue to work for large numbers of clients if they are not disciplined in some way—by the prospect of being thrown out in an election for instance—and episodes of burning tires in the streets are unlikely to produce sustained results unless they are accompanied by the kind of “linear process of negotiation, deliberation and consensus seeking” that these authors seem to belittle.⁷⁵ The danger in relying on the politics of patronage, as Harri Englund puts it, is that “Under the conditions of rampant poverty and political turmoil, intermediate solidarities can quite as much support warlords as moral ethnicities.”76 If civic politics rarely dispenses with patronage relationships, patronage without civic politics can lead to the mobilization of strong-armed clienteles clashing with other clienteles, all the more dangerous when such collectivities follow ethnic lines.

We see here a new form of tensions that have long been part of the vitality of African societies, between kinship groups and kingdoms or empires, between attachment to locality and mobility, between attachment to local symbols and adherence to wider religious communities. The supposed intimacy of the “group” may conceal oppression and hierarchy, and the supposed egalitarianism of the civic may leave politics remote from lived experience and thereby encourage the communalism that the civic was supposed to avoid. Citizens’ engagements with each other play out in a wide field, beyond state boundaries. Especially since World War II, Africans have migrated to many parts of the world seeking work, sometimes acquiring citizenship in host countries, but often retaining ties to their countries of origin and sending remittances “home” to sustain families, build houses and mosques, and contribute to government coffers—a diasporic citizenship in action.⁷⁷

Whether such tensions lead to violent conflict or to oppressive state structures intended to suppress tensions or else to creative forms of federalism and attempts to balance different kinds of attachments is a question whose stakes are high. Ethiopia, for instance, adopted in 1995 a constitution that referred, using plurals, to “We, the Nations, Nationalities and Peoples of Ethiopia.” Federation did not come about through the uniting of preexisting units, but followed a plan laid out by the central government. Of some 80 ethno-territorial units in Ethiopia, only six received the status of a “mother state.” But the federal structure did give recognition to ethnic diversity and devolved, for a time, significant power to provinces. Lahra Smith argues that the system was intended to produce “meaningful citizenship”—attuned to people’s perception of themselves and to the importance of different collectivities making claims for resources on the federal state. It worked better in some regions than others, but the gestures toward decentralization were soon overwhelmed by the ruling elite’s urge to do whatever necessary to remain in power, hence “rather familiar patterns of repression, authoritarianism, and narrowing of political space.”78

A counterpoint to the trajectories of citizenship in post–World War II tropical Africa is the case of South Africa in the years 1948–94, when a white minority ruled over a heterogeneous polity, denying people of African and Asian origin political voice and subjecting them to harsh policies of racial discrimination and exploitation, a policy known as apartheid (from the Afrikaans word for separate). Apartheid evolved into something of a caricature of the politics of citizenship in the decolonizing world. Earlier, South Africa’s racial politics fell well within the spectrum of twentieth-century colonialism, with its invidious racial distinctions. In the late nineteenth century, tensions between the English- and Afrikaans-speaking white populations made it difficult for either to identify fully as “British” or “South African,” but they could agree on distinguishing themselves from indigenous people or South Asian immigrants.⁷⁹ “South African” came to mean “white South African.” After achieving self-governing status within the British Commonwealth in 1910 and coming under control of a self-consciously Afrikaner political movement in 1948, South Africa took a different course from other British territories. South African elites turned white domination from an imperial into a national project, an expression of self-determination by a self-styled “people” to rule over a territory.

As colonialism and white domination came under fire in international circles, South Africa’s government kept trying to echo the ideological framework of the rest of the world. Africans would benefit from “separate development,” comparing favorably, so it was claimed, to the material possibilities of “developing” African countries. Then, South Africa asserted that the territories that had been “reserved” for Africans—a small fraction of the total farmland for a large majority of the population—constituted their genuine places of belonging and would become self-ruling in their own way. Africans would not be citizens of South Africa—not even second-class citizens—but citizens of Kwa Zulu, Bophuthatswana, or some other entity defined by a supposed ethnicity. Although the “white” economy depended on “black” labor, most Africans were considered as temporary workers (although others were granted residence rights in a complex structure of urban control manipulated by the state), who could only claim citizenship in their homeland. This tactic did not gain recognition from outside powers, and it did not end the claims of black South Africans to be equal citizens of a democratic South Africa. And while a small elite in each of the “nations” could profit from collaboration with the South African state—building patronage networks and a small state apparatus around them—black South Africans continued to demand the full rights of the South African citizen.80

After the colonial order collapsed around the world, maintaining racial domination in one country proved an impossible task. The government negotiated with the African National Congress for a peaceful transition to majority rule. As black South Africans flocked to the electoral bureaus for the first time in 1994, the appeal of an inclusive citizenship triumphed over the tendencies that divided citizenship had previously entailed. Citizens of South Africa have claimed social and economic as well as political rights, and the government has to a certain extent responded: supplying once-segregated, deprived urban areas with electricity and piped water, and extending pensions and welfare benefits to Africans once deprived of them, so that around 30 percent of the population is now receiving some kind of cash benefit from the state.81 But South Africa—despite the vigorous embrace of political participation by its population and the end of legally sanctioned racial discrimination—remains one of the most unequal countries in the world. Its elite is no longer lily-white; its poorest people are almost entirely black; and controversy prevails in South African politics over both the gap between rich and poor and the corruption that grows out of patron-client relations. One response to the clash of aspirations and realizations has been to blame noncitizens, and episodes of xenophobic violence directed against Africans from neighboring countries have besmirched the triumph of a racially inclusive citizenship regime (see above).⁸²

Some of the worst human consequences in Africa have followed from attempts to make state conform to nation. The failed secession attempts of Biafra from Nigeria and Katanga from the Congo in the 1960s led to years of violence. The attempt by Rwandan rulers to purify their state of its Tutsi citizens ended up in the genocide of 1994. The successful secession of Eritrea from Ethiopia produced a brutal state with little respect for the rights of citizens whose independence it claims to have won, and the successful secession of South Sudan from Sudan quickly led to a civil war between two claimants to power, each of whom mobilized ethnic divisions within the state. We see here the dangers of carrying a logic of group-based citizenship too far: there is no natural end point to the process of dividing people into categories that are supposed to represent authentic belonging and merit their own citizenship.⁸³

Beyond the question of locating citizenship is the question of what citizens gain from their relationship to states. The claims made against colonial states in the decades after World War II were not just for political voice but for a better life, and the first generation of African leaders appreciated the power of such claims. But could the “nation” fulfill them any better than had the colonial state, with its larger resource base and its belated recognition that its legitimacy depended on improving the material conditions of the people whose loyalty it wanted to command? The brittleness of newly independent states had much to do with rulers’ perceptions that it was extremely difficult for them to deliver their half of the citizenship bargain: decent services, decent life-chances, protection of rights in exchange for the orderly fulfillment of the citizen’s obligations to the state. The world recession and the drastic decline of African economies in the late 1970s, followed by rigid programs of cutting state services imposed on cash-starved African countries by international financial institutions, destroyed much of the gains made earlier in meeting citizens’ expectations.84 In such circumstances, the temptation was strong for rulers to act in authoritarian ways and for people to try to obtain via clientage what they could not get as rights-bearing citizens.

Patrons couldn’t necessarily deliver—a factor in the political convulsions in different African regimes in the 1990s. There was a certain, if halting and far from uniform, rhythm to the politics of citizenship in Africa: strong claims against colonial regimes—either to “thicken” imperial citizenship or obtain citizenship in an independent state—followed by a period of uneven efforts at forging development-oriented national states, followed by regression of both social progress and citizenship politics, and more recently a tenuous and uneven process in which some countries have experienced a revival of democratic elections, open debate, and renewed development efforts and others have experienced societal breakdown and warlordism. The mixture of vertical—patron-client—relations and horizontal—of citizens acting as such to place demands on the state—has been complex and volatile.85

What is left of the desires of many African political actors on the eve of independence to look beyond the territorial nation-state toward some form of federation? Three days after the collapse of the Mali Federation in August 1960, Senghor told a press conference, “Of course the federation remains an ideal. We are forced to admit that it remains a distant ideal. It cannot be realized if African states have not moved beyond their territorialism.”⁸⁶ Territorialism characterized Senghor’s Senegal as much as his rival’s Côte d’Ivoire. Can it be overcome? The African Union, successor to the Organization of African Unity, has made modest institutional efforts to foster cooperation among states, but it has not overcome its predecessor’s tendency to protect heads of state, intervening in some cases where state-based order has completely broken down but little inclined to raise questions about violations of civil, political, or human rights by member states. The clearest signs of progress are the regional associations of states, ECOWAS in West Africa and SADCC in southern Africa, limited by the same deference to heads of state, fears that such organizations could become tools of the most powerful member states, notably Nigeria and South Africa, and, in the case of peacekeeping missions, the tendency of soldiers to act as badly as those of the warlords or oppressive rulers who were the object of intervention. A small but hopeful sign: on visiting Ghana a few years ago, I saw that the direction sign at Passport Control did not distinguish foreigners from Ghanaians, but foreigners from citizens of ECOWAS countries, similar to the signs one sees on entering the European Union.

Post-Imperial Citizenship in the European Union

The end of empire meant the separation of citizenships, but for France what ensued was both a narrowing and an expansion, narrowing in relation to Africa, expanding in relation to the rest of Europe. From 1948 to 1957, the leading French architects of European unity had argued that what should be created was in fact “Eurafrica,” folding a Franco-African federation or confederation into a European confederation. To do otherwise would split France in two. African leaders took this possibility seriously, insisting that if Eurafrica came into being they should have a voice in it, just as they would have to have an equal voice as citizens of a Franco-African polity. With the final negotiations in 1957 to create the European Economic Community, it became clear that France’s would-be partners did not want to take on the burdens of an ex-empire. France’s African territories were relegated to the status of “associates” rather than members of the Community—with certain economic benefits but no voice. The European Economic Community would indeed be European.

In the 1990s, when the idea of a political as well as an economic European Union came back on the agenda, France joined its partners in creating a European citizenship. Citizenship in a Member State—France, Germany, Italy, etcetera—automatically conveys “citizenship of the European Union,” a status to be duly imprinted on each person’s passport. What European citizenship entails is a matter of controversy. With freedom of movement within the Union, citizens of one Member State have access to at least some of the social entitlements of the state in which they find themselves, and in some cases they have the right to vote in local (but not national) elections. They have the right to petition the European Parliament and to bring a legal case against their own state in European courts.87

Commentators have not dwelt on the fact that this citizenship strongly resembled the “superposed citizenship” that had briefly been offered to the nationals of the Member States of the French Community in 1959. France decided that it liked the idea of confederation and shared citizenship after all, but with the relatively affluent states of Europe and not with the much poorer states whose destiny had once been attached to France by colonization.

Now, years after the separation of citizenships, many people whose parents or grandparents had between 1946 and 1960 moved between African and European France with the rights of citizens are risking their lives to cross the Mediterranean to enter—without papers—a space that is European more than it is French. But the task of governing European space is not an easy one, not least where it comes to regulating legal and illicit immigration. The influx of migrants from war-torn or desperately poor parts of what used to be European empires has unleashed tensions between governments like that of Germany that favored (although more clearly in 2015 than more recently) a relatively liberal attitude toward integrating refugees into the social fabric and those like Hungary (in denial of much of its own history) that prefer to build walls.

These conflicts are part of a deeper tension between the parochialism of nation-state politics in the Member States of Europe and the vision of a coordinated European system. Europe is not a state—although it exercises an array of state-like functions—and its citizenship and its powers derive from its Member States.⁸⁸ Union institutions have a great deal to say about economic interaction, especially the free movement of capital, goods, and people. Social benefits, however, are largely a matter for each Member State to determine, although they apply—with controversies over exactly how—to both citizens of other European states and other legal residents. That poses a political problem, for the Union places fiscal constraints on each state. Especially in hard economic times—like the present—austerity is imposed on each state from what seem like distant European institutions, “dethroning politics in the name of market discipline,” pushing each state “to erode social rights by necessity.”89 Told that the implacable laws of economics leave their governments no choice but to lay off civil servants or diminish benefits, many citizens in different Member States search for scapegoats—foreigners, refugees, or the European Union itself.

The strongest institutions of the Union—the European Commission, the European Central Bank, the courts—are the most removed from the controls of electoral democracy. European citizens aren’t sure what the European Parliament does. Critics worry that “The technocratic basis of supranational authority is deeply at odds with the democratic presumption that citizens are competent judges of matters of public interest.” Although the European citizen, even in a Member State other than his or her own, can make claims through legal action, strikes, demonstrations, and in some instances votes, such a person is regarded in some eyes as a “taxpayer” and “user” of services more than as a politically engaged person.⁹⁰

This depoliticizing of citizenship is not unique to the European Union. When states—in the Americas, Africa, or elsewhere—outsource services to private enterprises, social benefits are distanced from the citizen’s direct control. When African states rely on international NGOs to provide medical care, education, or other social services, they transfer accountability from citizens to foreign donors.⁹¹ What is at stake in debates over how and by whom social programs are administered is the relationship between the social and the political, between the citizen as recipient and as actor in the organization of collective life.

Social Citizenship between Empire and Nation

The gains that European welfare states achieved occurred when a large portion of the people living under the jurisdiction of those states—in the colonies that is—were excluded from the benefits of social democracy. Because imperial polities like France and Britain insisted that colonized people were inside the polity, that they belonged there, that their consent and cooperation in peacetime and wartime helped make the polity strong, that there really was no other place colonized people could be, the question of what their place in the structures of imperial inclusion had to be confronted in one way or another. Although for a considerable time the distinction between the colonized subject overseas and the politically empowered citizen at home seemed to many to be natural, it kept coming under interrogation by pesky intellectuals and politicians who took their republican or democratic ideals seriously, by humanitarians of various persuasions, and most importantly by colonized people themselves who laid claim to the rights of the imperial citizen. That other activists sought to overturn colonial rule altogether raised the stakes politicians on both sides of the colonial divide had in finding the middle ground of imperial citizenship. Claim-making and political mobilization played out not just in the context of relations between colonizers and colonized, but of inter-empire rivalries that periodically underscored empires’ need for the loyalty of the people they were trying to keep in a subordinate position.

When in the mid-twentieth century the states of western Europe deepened social benefits and worker protections into a basic element of citizenship, it was not so easy to segregate access to them. By the late 1940s, political and social movements in different imperial regimes were demanding the social as well as the political prerogatives of citizenship—of imperial citizenship, that is. Such demands could be and were resisted, but in the climate of uncertainty and potential conflict after the war, they were hard to ignore. The rising costs to imperial powers of social citizenship—not just the costs of administration and repression—made both colonialism as it had previously been practiced, as well as post-imperial federalism, seem like expensive alternatives to letting colonies go.

African states would have to fend their way, responding—or not—to their citizens’ demands with their own resources. Before 1960, French Africans could demand as citizens that the French government provide resources for education, health, economic development, and welfare, sometimes with results. After independence, their governments could ask for foreign aid.92 Or else, individuals could attempt to migrate, illegally or otherwise, to Europe or North America. This history of connection and disconnection—of imperial inclusion and republican exclusion—lies behind the resentments of Africans who have made it into Europe and the anxiety of Europeans in the face of people from Africa and Asia coming to their shores. What is perceived as a problem of “immigration” has deeper historical roots in the division and redivision of the world into imperial and national units.

When Senghor in 1960 warned against “territorialism”—he had previously used the word “balkanization”—among African states, he was pointing to a problem that would bedevil his own Senegal, but also the rest of the world, Europe as well as Africa. He understood quite well that independence stood in relation to interdependence. Today, we are frequently told that we must adjust our expectations of what national states can provide to the imperatives of “globalization,” but interdependence is not particularly new, and the connections involved are more specific than the term globalization suggests. The basic problem is fundamental. For a time, political leaders, intellectuals, and international relations specialists thought that a world of juridically equivalent, sovereign nation-states would be more manageable, its conflicts more defined, than the non-equivalence of political units in the age of imperialism, some of which might attempt to subordinate the others, as indeed had happened in the times of Charlemagne, Charles V, Napoleon, Hitler, and Stalin.

The violence of wars of global domination, the violence of colonial conquest, and the routinized violence of maintaining colonized people in a state of dependence and inferiority have, it seems, been consigned to the past. The banishment of colonial empire not just from the repertoires of geopolitical strategy but from the realm of the politically defensible has been the great achievement of activism in the colonial world, after decades of nonviolent mobilization as well as armed struggle. What is less clear is whether the world of juridically equivalent nation-states that has in principle replaced it can bring about the stability or the spread of social and economic progress that inspired the hopes of social and political movements. The sovereign state has become the general form of polity, but citizenship still does not have a common political, civic, or social significance. The relationship of “people,” “a people,” and “the people” to each other and to territory has been and remains ambiguous and contested.93 The possibility of “civic nationalism”—where the sense of commonality flows from the project of building a democratic polity itself—has been a noble answer to a complex question, and in some parts of the world it has produced a convincing narrative. But it has never been a particularly stable one, and civic nationalism, as in post-1994 South Africa, has not proved immune from xenophobia.

It was only in the latter half of the twentieth century that citizenship in a territorially defined state came to be widely accepted as a universal norm. The point is neither to celebrate nor condemn the division of the world into national citizenships, but to understand the possibilities and limitations of the framework that has so recently emerged as the norm, in the face of both the defense of the colonial order and a range of alternative postcolonial futures. The end of colonial empires and the fiction of equivalent sovereignties have at least made it possible to think about global inequality, even if the forces exacerbating it now seem stronger than those inhibiting it. A half century after the collapse of colonial empires, we are left not with a sense of the triumph of aspirations for equality among states and among peoples, but with a profoundly unequal world, in which citizenship is both a powerful means for claiming resources and articulating a sense of belonging, and a concept in deep tension with the way people think of themselves and the way in which economic and political power is exercised.

The making and breaking of historical connections and both the diversity and the inequality of relationships across space leave many people uncertain of where they have a right to be, about their sense of belonging to different kinds of collectivities, about where they can exercise certain rights, about where their voices can be heard. Scholars have tried to address such issues by turning to concepts like flexible or multilevel citizenship, and at times political leaders have tried, however imperfectly, to give legal substance to such notions. Some people yearn for a citizenship that is thick in its subjective and material sustenance. Some want above all to focus the benefits of citizenship on a body they think of as a coherent whole. Many worry about the thinning out of the material benefits citizens once expected from membership in a political community. These problems are not new, and they are not about to disappear.